Under Contract No. DTR56-96-C-0003, the Office of Pipeline Safety (OPS) tasked PCCI to examine OPS's onshore pipeline response plan review results from the implementation of 49 CFR 194, Response Plans for On-shore Oil Pipelines. PCCI examined the plan review results in the initial plan submission period and identified industry-wide trends and measures. OPS also requested PCCI to analyze OPS findings contained in twenty OPS spill response exercise reports. OPS provided response management training and assistance through its drill program. Since OPS uses operator response plans to design exercises or drills, OPS was interested in the impacts on response planning as a result of the drill program.

Most onshore pipeline operators submitted their response plans to OPS in 1993-94 to meet the deadline foe developing and submitting plans as required by the Oil Pollution Act of 1990 (OPA 90) and 49 CFR 194. OPS reviewed 657 significant and substantial harm response plans submitted for approval and checked 786 substantial harm plans to see if the plans contained the required response planning elements in the regulation. OPS approved all 657 significant and substantial harm plans after three plan review rounds.

OPS approved only one significant and substantial harm plan after the first review round. After the second review round, OPS approved another 269 plans. For those plans that still has findings involving significant regulatory requirements in 49 CFR 194, OPS worked with the operators to correct all findings and obtain approval because of the OPA deadline. After this "third review round", OPS approved the remaining 387 plans.

In general, the review protocols that over 40 percent of plans did not adequately meet during the first review round were also the protocols that continued to be the ones that operators still needed to address adequately after the second review round. Among the three operator size categories, small, medium and large, large operators had the lowest success rate in correcting deficiencies from the first review round. There are several reasonable explanations. Pipeline operators had to develop response plans for the first time to comply with a new statute (OPA 90) and a new regulation (49 CFR 194). Unlike the other OPA 90 regulations developed by other federal agencies with responsibility for carrying out the statutory provisions of OPA 90, 49 CFR 194 has a less prescriptive and more generalized regulatory requirements. On the other hand, OPS had very specific review criteria as reflected in the review protocols. Operators appeared to have difficulties in interpreting what the rule required and not be aware of the specific response planning aspects that had to be addressed and to what detail in the plans for OPS to approve their plans.

OPS has a valuable tabletop exercise program that provides realistic scenarios to test operator response plans. OPS is discovering weaknesses in the plans that are likely to reduce response effectiveness in actual spill events. However, operators generally did revise their response plans to make use of the lessons and experience gained from the exercises.